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Tag: permanent establishment

Taxpayers who want to do business exclusively on the Polish territory, must take into account that their sorting plant was not considered to be a representative office or a permanent establishment within the meaning of OECD convention. This may result in the need to register with relevant authorities of the State in which the sorting plant is located.


Permanent establishment means a fixed place of business through which the business of an enterprise is wholly or partially carried on.

The term permanent establishment includes especially:

  • a place of management,
  • a branch,
  • an office,
  • a factory,
  • a workshop.


An Avoidance of Double Taxation Agreement – the convention signed between Great Britain and Poland in 2006 specified this term.

In order to explain the difference between an agent of a dependent status and an agent of an independent status we need to provide explanation of a permanent establishment first.

The term permanent establishment – according to the CIT Act – means a fixed place of business through which the entity having a seat or management on the territory of a given country, wholly or partially carries on business of the enterprise on the territory of another country.